A trust was terminated in 2010 when the primary beneficiary died and assets were distributed to the remaindermen including several charities. There is no DNI but a large capital loss with selling the stocks in a down market. The regs say the carryforward is allocated to the remaindermen but does that include the charities? I've had one opinion that charities don't get k1s so the portion allocable to them is simply lost, but another that in this case you issue them k1s even though they can't use the loss. One charity did send me their TIN, unsolicited, which makes me wonder if they are expecting a k1, but the regs seem to be silent on the matter, and I haven't found any references that deal with this situation.
------------------------------------- K.Jennings